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ESTATE OF ABRAHAM v. COMMISSIONER

Docket No. 7071-01.

87 T.C.M. 975 (2004)

T.C. Memo. 2004-39

Estate of Ida Abraham, Deceased, Donna M. Cawley and Diana A. Slater, Administratrixes v. Commissioner.

United States Tax Court.

Filed February 18, 2004.

Attorney(s) appearing for the Case

Brendan J. Shea, for the petitioner.

Carina J. Campobasso, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

RUWE, Judge.

The Estate of Ida Abraham (the estate) seeks a redetermination of respondent's deficiency determination of an estate tax of $1,125,210. The sole question presented is whether the full date of death value of three family limited partnerships is includable in the taxable estate of Ida Abraham (decedent) under section 2036.1 Respondent concedes that decedent received $320,000...

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